Introduction to Hazardous Introduction to Hazardous Waste Regulations: Waste Regulations: Paperwork Requirements & Paperwork Requirements & Inspection Day Inspection Day – – What to Expect What to Expect Michigan Department of Michigan Department of Environmental Quality Environmental Quality
60
Embed
Introduction to Hazardous Waste Regulations - michigan.gov · question/chat box We will record webinar and post online. ... - Response actions for fires & explosions - Response actions
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Introduction to Hazardous Introduction to Hazardous
Waste Regulations:Waste Regulations:
Paperwork Requirements & Paperwork Requirements &
Inspection Day Inspection Day –– What to ExpectWhat to Expect
Michigan Department of Michigan Department of
Environmental QualityEnvironmental Quality
HousekeepingHousekeeping
�� All lines will be mutedAll lines will be muted
�� Questions can be sent to us via the Questions can be sent to us via the
question/chat boxquestion/chat box
�� We will record webinar and post We will record webinar and post
Apply to all businesses, including Apply to all businesses, including
municipalities, hospitals, & service municipalities, hospitals, & service
industries, not just manufacturing industriesindustries, not just manufacturing industries
Are written broadly to address hazards Are written broadly to address hazards
posed by all waste streamsposed by all waste streams
Why Cover These Topics?Why Cover These Topics?
Hazardous waste regulations Hazardous waste regulations require each business torequire each business to……
Properly prepare, maintain, and have Properly prepare, maintain, and have available at the time of inspection all available at the time of inspection all documents documents required under RCRA and required under RCRA and
Part 111 rulesPart 111 rules
Keep all documents Keep all documents onon--sitesite for a period of for a period of not less than 3 years from the last date of not less than 3 years from the last date of hazardous waste shipment offsitehazardous waste shipment offsite
PAPERWORKPAPERWORK
REQUIREMENTSREQUIREMENTS
Notification of Waste Activity (Site ID)Notification of Waste Activity (Site ID)
Waste CharacterizationsWaste Characterizations
Manifests & Shipping RecordsManifests & Shipping Records
Land Disposal Restriction Forms (LDRs)Land Disposal Restriction Forms (LDRs)
Waste Area Inspection Documents Waste Area Inspection Documents
Copy left at time of shipment is called the “two signature or generator copy.”
Copy sent to generator by disposal facility is called the “third signature or
TSD copy.” It verifies that waste was delivered to disposal facility. Match this copy to the generator copy.
LAND DISPOSAL LAND DISPOSAL
RESTRICTIONS (LDR) OVERVIEWRESTRICTIONS (LDR) OVERVIEW(Rule 311 and 40 CFR 268)(Rule 311 and 40 CFR 268)
Applies to hazardous wastes from SQGs & LQGsApplies to hazardous wastes from SQGs & LQGs
Requires generator to characterize, provide an Requires generator to characterize, provide an LDR notice to each TSD for each waste stating LDR notice to each TSD for each waste stating waste does or does not meet LDR standardswaste does or does not meet LDR standards
Requires treatment before land disposal for most Requires treatment before land disposal for most wastes wastes
To determine if treatment is required, review if To determine if treatment is required, review if waste codes for each waste stream meet the waste codes for each waste stream meet the standards in 40 CFR 268.40, 268.45 (debris), standards in 40 CFR 268.40, 268.45 (debris), or 268.49 (soil).or 268.49 (soil).
New LDR notification must be sent when there New LDR notification must be sent when there is a waste or facility change.is a waste or facility change.
LAND DISPOSAL LAND DISPOSAL
RESTRICTIONS (LDR) OVERVIEWRESTRICTIONS (LDR) OVERVIEW(Rule 311 and 40 CFR 268)(Rule 311 and 40 CFR 268)
LAND DISPOSAL LAND DISPOSAL
RESTRICTIONS (LDR) OVERVIEWRESTRICTIONS (LDR) OVERVIEW(Rule 311 and 40 CFR 268)(Rule 311 and 40 CFR 268)
Land disposal includes any disposal on land (landfill, Land disposal includes any disposal on land (landfill,
land treatment, injection well, salt caverns, etc).land treatment, injection well, salt caverns, etc).
Notification is required even for shipment to Notification is required even for shipment to
nonnon--land based TSDs (e.g. incinerator).land based TSDs (e.g. incinerator).
Generators treating a prohibited waste to meet the Generators treating a prohibited waste to meet the
standards in 40 CFR 268.48 must have a written standards in 40 CFR 268.48 must have a written
waste analysis plan describing the activities they waste analysis plan describing the activities they
perform to meet the treatment standards.perform to meet the treatment standards.
All generator LDR records are required to be All generator LDR records are required to be
maintained for 3 years from the last date of maintained for 3 years from the last date of
shipment or onshipment or on--site treatment and/or disposal, site treatment and/or disposal,
whichever is later.whichever is later.
LDR GENERATORLDR GENERATOR
RECORDKEEPINGRECORDKEEPING
LDR GENERATOR LDR GENERATOR
RECORDKEEPINGRECORDKEEPING
SQGs and LQGs must keep LDRs & related SQGs and LQGs must keep LDRs & related documents for at least 3 years after waste is last documents for at least 3 years after waste is last sent to TSD.sent to TSD.
LDRs must have complete information such as LDRs must have complete information such as categories of waste and underlying hazardous categories of waste and underlying hazardous constituents.constituents.
Information on LDR must be consistent with theInformation on LDR must be consistent with thewaste characterization.waste characterization.
Submit to RMD by March 1 of Submit to RMD by March 1 of eveneven--numbered yearsnumbered years
Report includes both MI & EPA Report includes both MI & EPA hazardous wasteshazardous wastes
Details hazardous waste activity Details hazardous waste activity in previous odd yearin previous odd year
Keep copy at least 3 years from Keep copy at least 3 years from due datedue date
HAZARDOUS WASTE AREA HAZARDOUS WASTE AREA
INSPECTION DOCUMENTSINSPECTION DOCUMENTSSQG & LQG must perform weekly container accumulationSQG & LQG must perform weekly container accumulation
area inspections & each operating day for a hazardous area inspections & each operating day for a hazardous
waste storage tanks.waste storage tanks.
LQGs must LQGs must document document hazardous waste hazardous waste container container accumulation area accumulation area & tank inspections.& tank inspections.
EMERGENCY PLANNING & EMERGENCY PLANNING &
TRAINING REQUIREMENTSTRAINING REQUIREMENTS
CESQGs CESQGs
have no specific requirements!have no specific requirements!
EMERGENCY PLANNING & EMERGENCY PLANNING &
TRAINING REQUIREMENTSTRAINING REQUIREMENTS
-- Informal trainingInformal training
-- Training records not required Training records not required
-- Key parameters for automatic waste feed Key parameters for automatic waste feed cutcut--off systemsoff systems
-- Communications & alarm systemsCommunications & alarm systems
-- Response actions for fires & explosionsResponse actions for fires & explosions
-- Response actions for contamination incidentsResponse actions for contamination incidents
-- Shutdown of operationsShutdown of operations
PREPRE--TRANSPORT TRANSPORT
REQUIREMENTS REQUIREMENTS (Rule 305)(Rule 305)
If offering 1,000 lbs. for shipment at one time,If offering 1,000 lbs. for shipment at one time,
SQGs and LQGS must have US DOT placards forSQGs and LQGS must have US DOT placards for
waste hazards available for transporters use.waste hazards available for transporters use.
TANKTANK
INSPECTION DOCUMENTSINSPECTION DOCUMENTS
All tank inspections must be All tank inspections must be
documented and all recordsdocumented and all records
must be kept for at least 3 years.must be kept for at least 3 years.
TANK CERTIFICATIONTANK CERTIFICATION
Part 111, Rule 306 & 40 CFR 265.192Part 111, Rule 306 & 40 CFR 265.192Must obtain a written assessment that is reviewedMust obtain a written assessment that is reviewed
and certified by an qualified professional engineer and certified by an qualified professional engineer
that includes:that includes:
�� Design standardsDesign standards
�� Hazard characteristics of the wasteHazard characteristics of the waste
�� Determination performed by corrosion expert if the Determination performed by corrosion expert if the external shell of a metal tank is in contact with soil external shell of a metal tank is in contact with soil or wateror water
�� Design considerations if tank affected by vehiclesDesign considerations if tank affected by vehicles
TANK CERTIFICATIONTANK CERTIFICATION
Professional engineer written certificationProfessional engineer written certification
must be kept on file at facility.must be kept on file at facility.
INSPECTION DAY !INSPECTION DAY !
INSPECTION DAY!INSPECTION DAY!
When & why does an inspector visit?When & why does an inspector visit?
Routine compliance inspection utilizing aRoutine compliance inspection utilizing a
““Neutral Criteria PlanNeutral Criteria Plan””
Complaint receivedComplaint received
Manifest discrepanciesManifest discrepancies
Inspection requested by another agencyInspection requested by another agency
HOW TO SURVIVE AN HOW TO SURVIVE AN
INSPECTIONINSPECTION
Relax!Relax!
DonDon’’t be adversarial.t be adversarial.
Have your records in order.Have your records in order.
DonDon’’t try to hide anything.t try to hide anything.
If asked to If asked to ““fixfix”” something, consider doing it something, consider doing it
Using wrong or incompleteUsing wrong or incomplete
waste codeswaste codes
Failing to send copy to state Failing to send copy to state
Failing to keep signed Failing to keep signed
manifests for three years manifests for three years
Failing to have records of Failing to have records of
used oil shipped onused oil shipped on
consolidated manifestconsolidated manifest
LDR COMMON VIOLATIONSLDR COMMON VIOLATIONS
Failing to keep LDRsFailing to keep LDRs & related documents& related documents for at for at least 3 years after waste last sent to TSDleast 3 years after waste last sent to TSD
Missing LDRMissing LDR notificationnotification and waste analysis and waste analysis documentsdocuments
Missing or incomplete informationMissing or incomplete information such as such as categories, underlying hazardous constituents, categories, underlying hazardous constituents, and manifest numbersand manifest numbers
Listing LDR information that is inconsistent with Listing LDR information that is inconsistent with waste characterizationwaste characterization
Failing to have Failing to have
adequate space or adequate space or
aisle width to aisle width to
properly inspect properly inspect
containers and for containers and for
emergency personnel.emergency personnel.
Failing to have Failing to have
labels visible labels visible
for inspections.for inspections.
Leaning drumLeaning drum
is a safety issueis a safety issue!!DonDon’’t stack more than 2 drums hight stack more than 2 drums high
COMMON STORAGE VIOLATIONSCOMMON STORAGE VIOLATIONS
���� Exceeding the allowable onExceeding the allowable on--site accumulation time site accumulation time
limit for hazardous waste without requesting anlimit for hazardous waste without requesting an
extension or obtaining a storage permitextension or obtaining a storage permit
Notice leaking drums and stainsNotice leaking drums and stains
COMMON STORAGE VIOLATIONSCOMMON STORAGE VIOLATIONS
�� Failing to keep the Failing to keep the
containers closed, except when containers closed, except when
waste is added or removedwaste is added or removed
COMMON STORAGE VIOLATIONSCOMMON STORAGE VIOLATIONS
Notice the stainingNotice the staining� Failing to have Failing to have
Containers elevated or Containers elevated or
base of containmentbase of containment
sloped to drain when sloped to drain when
requiredrequired
� Lacking or Lacking or
inadequate squirt inadequate squirt
protection protection
COMMON SECONDARYCOMMON SECONDARY
CONTAINMENT VIOLATIONSCONTAINMENT VIOLATIONS
� Lacking or inadequateLacking or inadequate
chemical resistant coating & chemical resistant coating &
having cracked surfaceshaving cracked surfaces
COMMON SECONDARYCOMMON SECONDARY
CONTAINMENT VIOLATIONSCONTAINMENT VIOLATIONS
How can drums be checked for leaks if How can drums be checked for leaks if
buried in snow?buried in snow?
�� Failing to Failing to
remove remove
precipitation in aprecipitation in a
timely manner timely manner
from containment from containment
areasareas
COMMON SECONDARYCOMMON SECONDARY
CONTAINMENT VIOLATIONSCONTAINMENT VIOLATIONS
Sloping ramp saves backs and Sloping ramp saves backs and
reduces spills when moving reduces spills when moving
materials in & out of materials in & out of
containment areacontainment area
Spill pallets ok for solids but Spill pallets ok for solids but
does does NOTNOT provide squirt provide squirt
protection for liquidsprotection for liquids
This type does This type does
provide squirtprovide squirt
protectionprotection
COMMON SECONDARYCOMMON SECONDARY
CONTAINMENT OPTIONSCONTAINMENT OPTIONS
Sorbents can be landfilled Sorbents can be landfilled IF IF theythey
dondon’’t contain free liquids, t contain free liquids, ANDAND
are not a hazardous waste, ORare not a hazardous waste, OR
were generated by a CESQG.were generated by a CESQG.
Sorbents used to clean Sorbents used to clean
up hazardous waste by up hazardous waste by
SQG or LQG SQG or LQG mustmust be be
handled as hazardous handled as hazardous
waste.waste.
SORBENTSSORBENTS
WHAT KIND OF INSPECTION WHAT KIND OF INSPECTION
FOLLOW UP IS NECESSARY?FOLLOW UP IS NECESSARY?
Respond according to the letter sent Respond according to the letter sent by the RMD.by the RMD.
Accompany inspector if there is a Accompany inspector if there is a followfollow--up second inspection.up second inspection.
Have a question about the Have a question about the inspection? Call the inspector who inspection? Call the inspector who visited your facility.visited your facility.
Have general waste question? Have general waste question? Contact the Environmental Assistance Contact the Environmental Assistance Center at 800Center at 800--662662--9278 or 9278 or